SpeakTheSame Privacy Policy

 

 

Effective as August 8th, 2020

 

Welcome to SpeakTheSame!

 

We are committed to protecting the privacy and the security of the personal information (“Personal information”) we collect from our clients (“you”) in the regular course of doing business.

 

What kind of Personal information do we collect?

 

This will depend on the type of product or service that you have requested from SpeakTheSame. 

 

We will only collect Personal information that is required to provide you with the products and services you request, and only by reasonable and lawful means.

 

We use and disclose your Personal information only for the purposes for which it was collected unless permitted by law. We will not use Personal information for any additional purpose unless we seek your express written consent to do so. We will tell you the purpose(s) for which your Personal information is collected at the time of collection. We do this explicitly or by implication where the purpose of using such information is reasonably apparent to you by virtue of its nature or the context in which it is being collected.

What is Personal information in the first place?

 

Personal information means any information whether factual or subjective, recorded or not that relates to an identified or identifiable individual.

 

The Personal information that we may collect from you may include your name, address, postal code, phone number, email address, service history, service preferences, customer satisfaction info, or even opinions about products and services.

 

This means that if different elements of information, collected together, can be used to identify a particular person, then such elements of information constitute Personal information. 

 

Personal information that have been de-identified or stripped from strict identifiers, encrypted or pseudonymized but can still be used to re-identify an individual also constitutes Personal information. On the other hand, Personal information that has purposefully been rendered anonymous to the extent that an individual cannot or no longer be identifiable is not considered Personal information.

 

What is not considered Personal information may therefore include: anonymized information; business contact information; a business registration number; a business email address; public telephone directory information; professional and business directories available to the public.

How does it work?

 

The data we collect about you is received from you directly. We may also collect information from third parties outside SpeakTheSame, including:

 

  • Persons authorized to act on your behalf under a power of attorney or other legal authority;

  • Service providers, agents and other organizations with whom you or we conduct business;

  • Government agencies and public registries.

 

The decision to provide us with your Personal information always rests with you. 

 

We keep your Personal information only as long as it is required for our business relationship or as required by applicable laws. Subject to any requirements to retain information, SpeakTheSame will ensure that Personal information that is no longer required will be safely destroyed, erased or made anonymous.

 

How do we protect your Personal information?

 

SpeakTheSame is responsible for all Personal information in its possession or control. We respect the privacy rights of all individuals whose Personal information we may have and use. We are committed to protecting your Personal information in our possession or controlling it from loss, theft, alteration and misuse.

 

We use a variety of security measures to protect your Personal information including: (i) restricted access facilities and locked filing cabinets; (ii) shredding of documents containing Personal information; (iii) electronic safety measures such as password protection, database encryption and personal identification numbers; (iv) organizational processes such as limiting access to your Personal information to a selected group of individuals; and requiring third parties given access to your Personal information to protect and secure your Personal information. The safeguards we employ to protect your Personal information depend on the sensitivity, amount, distribution, format and storage.

What about consent?

We will obtain your consent prior to collecting, using or disclosing your Personal information. The method of obtaining consent will be appropriate to the type of service that we perform.

Therefore, we will seek your express consent (verbal, written or electronic) when the Personal information is sensitive or its collection, use or disclosure is outside of the reasonable expectations of you providing it, or that creates a meaningful risk of significant harm that is not otherwise mitigated.

 

We will rely on your implied consent to collect, use or disclose your Personal information, where one or more of the following apply:

 

  • We already have a customer relationship;

  • You previously gave us your express consent for the same or similar use;

  • The purpose of using your Personal information is reasonably obvious from the context in which it is obtained, considering that you provide the information voluntarily.

 

In limited circumstances will we collect, use and disclose your Personal information without your consent, including: (i) If permitted or required by law; (ii) In an emergency situation that threatens an individual’s life, health or personal security; (iii) If there is a reason to suspect that you may be a victim of fraud or abuse and we need to disclose the Personal information to a government institution or authorized representative for investigation and follow-up; (iv) In connection with an investigation or proceeding by us or a law enforcement organization and (vi) If certain information is publicly available.

 

How do I withdraw consent?

 

You may withdraw your consent to any collection, use or disclosure of your Personal information, at any time on reasonable written notice, subject to permitted or required exceptions under applicable privacy laws. We will do our best to provide reasonable alternative arrangements. However, in some situations, withdrawal of consent may also deprive you of a service.

 

To change your consent to collection, use or disclosure of your Personal information about you, please don’t hesitate to contact us.

Can I access my Personal information?

 

You can request access to your Personal information we keep by making a request at any time. SpeakTheSame may reserve it’s right to decline to make a requested correction but we will append a notation to the record of your requested alternative information; and we will update your Personal information.

 

We may not be able to satisfy your request subject to applicable exceptions under applicable privacy laws, whereas: (i) your request would divulge confidential competitive business information of SpeakTheSame; (ii) the data is not readily retrievable and the burden or cost of providing access is disproportionate to the nature of the request; and where access could interfere with or prejudice an investigation or proceeding by SpeakTheSame or law enforcement agencies.

What about this website and statistics?

 

To continually improve our Website and our online services, we may collect information about how you are using it. These usage statistics are only viewed in the aggregate – and are never tied to an individual. We use this information for purposes such as improving the pages where our customers are having difficulties and ensuring that we have the appropriate infrastructure in place to service future needs. The information collected may include your location, your IP address, your browser type and your operating system, as well as data that is passively generated as you browse, such as the number and types of pages visited, and the length of time spent per page and on the Website overall.

Cookies

A cookie is a small information token that sits on your computer or mobile device. As you use any services offered through SpeakTheSame website, cookies are passed back and forth between our server and your browser. While cookies can be used for a variety of reasons, we will only use cookies where they are of benefit to our customers.

 

There are two kinds of cookies we may use – session cookies and persistent cookies. A session cookie exists only for the length of your browsing session and is deleted when you close your browser. A persistent cookie is a cookie that stays on your computer or mobile device after you close your browser. A persistent cookie may or may not expire on a given date. We use a session cookie to maintain the integrity of your internet session. With each page that you visit, the cookie is passed back and forth between our server and your browser. We use the cookie to distinguish your session from the many others that may be happening at the same time. Our session cookies never store any personal data such as your name, or date of birth, or financial information, such as your accounts and balances.

 

Recent browser versions allow the user to set some level of control over which cookies are accepted and how your browser uses them. Browsers will allow you to accept cookies from only known, reliable sites that you select such as the SpeakTheSame website. If you are concerned about cookies, we encourage you to upgrade your browser to a recent version and review the Help section of your browser to learn more about its specific control features.

Email?

 

To communicate with us electronically, we strongly recommend that you use our “Contact Form” feature. This feature provides a secure channel for sending us comments, questions or instructions.

 

Email is not secure since it passes through many points on its route from you to us. If you are using general email to communicate with us, we strongly recommend that you do not include personal financial information (such as account numbers) within the email as we cannot guarantee its confidentiality as it comes to us. When you email us your comments, questions or instructions, you provide us your email address and we use it to correspond with you.

 

We will not provide your email address to anyone outside of SpeakTheSame. We may use your email address to send you information about products or services that we think may be of interest to you. If you do not want us to contact you with product information by email, you may tell us so at any time by using the “Contact” feature. We will discontinue the practice.

 

If you have asked us to provide you with information on a regular basis, or if we email you information about our products or services, you may ask us to remove you from the list at any time. We will include instructions to unsubscribe from the list in every mailing, and on the site where you originally subscribed to the list.

 

If you have any questions, concerns or complaints about our privacy policies or are uncomfortable about any information or requests you receive from SpeakTheSame via phone, or email, we encourage you to contact us immediately.  In most cases, any questions or concerns that you have can be resolved by discussing it with us. Thank you.